You may have seen news items in various TV news broadcasts and in the Whyalla News this week, bullishly reporting on the progress on IronClad Mining’s plan to export iron ore from Lucky Bay. Back in January, we wrote to the Federal Environment Minister, Mr Tony Burke, putting forward a case for the necessity of Federal environmental assessment. We are currently awaiting a response. The Development Application is currently undergoing 3 separate amendments, the details of which have not been disclosed to the public. We contacted both IronClad Mining and their consultants, Masterplan, asking for this information but neither party has been forthcoming. Below is the contents of our letter to Minister Tony Burke, sent on January 4th.

Dear Minister Burke,

Firstly, let me thank you for your department’s response to my recommendation that Centrex Metals’ Port Spencer proposed development on Eyre Peninsula be referred to the EPBC Act. I was pleased to see that your assessment ultimately determined the development to be Controlled Action.I now wish to recommend EPBC Act referral for another iron ore export development in Spencer Gulf: SeaSA’s Lucky Bay Harbor Expansion. This project (initially approved by the State of South Australia under Section 49 of the Development Act 1993, but now being re-assessed due to redesign of the project’s footprint) will see the existing SeaSA passenger ferry terminal expanded to facilitate the transhipping of containerised iron ore, and will bring with it unprecedented heavy truck and barge traffic (and with it disturbance and risk to EPBC Act listed species). By SeaSA’s own documentation (available at http://www.luckybayharbour.com ) the project’s operation will involve trucks and fork-lifts operating 24 hours a day, along with a barge. Road trains will arrive at the site approximately every 37.5 minutes or if B-doubles are used, trucks will arrive every 24 minutes.

** note: since drafting this letter, I see that the above website has been removed. Please contact the project proponents SeaSA for full and current documentation: http://www.seasa.com.au/

This activity is approved to occur immediately adjacent to a tidal creek which is habitat for hundreds of sea and shorebirds, as described in the Lucky Bay Master Plan Ecological Assessment document from 2010 (which was prepared well prior to this expansion plan being proposed). You can download this document here.

White-bellied Sea Eagles are recorded adjacent to the proposed Lucky Bay iron ore export site

“The importance of the tidal creek to the south west of the ferry terminal that is connected to Franklin Harbour and the Franklin Harbour Conservation Park environs (DEWHA Directory of Important Wetlands Franklin Harbour SA010) was identified as migratory wader and White Breasted Sea Eagle habitat and a decision was made to exclude the area from proposed development.” This site is immediately adjacent to SeaSA’s proposed iron ore export operation. Present EPBC Act listed species include:

In addition to author Larry Bebbington’s recordings and predictions of the region’s visitation by EPBC Act listed species, I also have concerns about impacts to the marine environment. As proposed, barges will be used to transport the ore to a transhipping point located immediately adjacent a proposed Marine park sanctuary zone (see diagrams attached), which is designed to protect habitat for the Weedy Sea Dragon (fully protected under the SA’s Fisheries Act). No mooring point is proposed to be constructed, so the actions of waiting vessels dropping anchor, shading and killing sea grasses (due to prolonged loading times) mobilising sediment and potentially dumping ballast water (containing invasive species) in this sensitive area threaten this proposed marine park’s conservation values.

SeaSA describe the marine environment at the location of their transshipping points as having ‘low biodiversity value’, but this is at odds with the concept of providing buffer zones around marine sanctuaries to minimise impacts from industrial activities such as this. They also present no data to justify this claim.

Other EPBC Act listed species have also been recorded near the terrestrial project site and transhipping points. The Atlas of Living Australia also shows additional records of Green Turtle, Loggerhead Turtle, White-bellied Sea eagles, Hooded Plovers and Fairy Terns (among many others) all occurring within 5km of the proposed project site. The site is also immediately adjacent to Franklin Harbor, which itself is a Nationally Important Wetland, according to the EPBC Protected Matters search tool.

Hooded Plovers

It is my firm belief that the State approval process (via Section 49 of the Development Act 1993) is currently allowing SeaSA to proceed with its project without due acknowledgement of, or responsibility taken for, the biodiversity and conservation value of the Lucky Bay coastal and marine environments. As such, I urge you to contact SeaSA and request they refer their project to the EPBC Act immediately.

I contacted the State Government previously about this matter back in August of 2012, and was unsatisfied by their lack of action on this serious conservation matter. I thank you for your attention and look forward to hearing from you.